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PeerBasis
Compensation Comparability Determination

Health Care Without Harm

Executive Director / CEO

EIN 522358837
VA · NTEE C05
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Gary Cohen, Executive Director / CEO ($176,115) against every comparable organization that fit the selection criteria — 15 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 33rd percentile of comparable organizationswithin the typical range

Benchmarked executive: Gary Cohen — reported title “PRESIDENT”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

15 organizations qualified on sector, size, and geography 15 within the band form the benchmarked peer set.

Distribution of comparable compensation

$7,491 total compensation of comparable organizations → $471,753 $176,115
$111,74110th
$161,39425th
$262,423Median
$351,03375th
$384,99090th
$176,115This org · 33rd
p10$111,741
p25$161,394
p50$262,423
p75$351,033
p90$384,990
$176,115

Comparable organizations

Each figure is Form 990 Part VII columns D + F (reportable pay plus other compensation and benefits; column F may include amounts from related organizations), normalized to VA cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
Manomet Inc MA$8,259,400 President $285,906 $266,088 2024
Center For Climate Integrity DC$8,235,380 President $415,785 $377,884 2024
Action For The Climate Emergency MA$8,209,858 Executive Director $207,346 $198,673 2023
Biodiversity Research Institute ME$8,199,685 Executive Director $339,997 $352,602 2024
Evergreen Collaborative WA$9,057,853 Executive Director Start April $238,221 $227,416 2023
🔒 10 more comparable organizations — included in the purchased report

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to VA cost of living and 2024 dollars. Click any organization to verify the figure on ProPublica.

Methodology

Comparable organizations were drawn from electronically filed IRS Form 990 returns and matched on sector (NTEE code), budget (a size-adaptive revenue band that tightens as the organization grows), and geography (same-state first, broadening only when too few peers qualify); every organization within the band forms the peer set. To compare fairly across regions and years, peer compensation is normalized to VA cost of living (BEA Regional Price Parities, 2023) and to the subject's filing year (CPI-U). The figure benchmarked is Form 990 Part VII, Section A, columns D + F — reportable pay plus other compensation, benefits, and deferred amounts (column F may include amounts from related organizations) — with the chief executive matched by role. Related-organization amounts (column E) and institutional trustees are excluded. Full methodology: peerbasis.org/methodology.

Sample, role match & sensitivity

Sensitivity — the subject's percentile under alternative compensation definitions:

BasisSubject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default33rd
Total compensation (D + F), as reported (no adjustments)27th
Reportable pay only (column D), adjusted27th
All sources (D + E + F), adjusted40th

If the percentile moves materially across these definitions, the result is sensitive to methodology choices, and the board should weigh which basis best fits its facts.

Rebuttable presumption of reasonableness · 26 CFR 53.4958-6

Compensation paid by a tax-exempt organization is presumed reasonable — shifting the burden to the IRS — when three requirements are met. This report supplies the comparability data for the second. The board should record the following in its minutes concurrently with its decision:

Ready-to-adopt board minutes — executive compensation

🔒 The complete minutes language — three numbered resolutions pre-filled with this organization, the 15-organization comparison, the date, and the percentile finding, ready to paste into your minutes — is included in the purchased report.

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Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). Every figure traces to an original public filing — click any organization above to verify it on ProPublica. PeerBasis is a service of Prismind Analytics; its methodology is published, was commissioned for independent adversarial review, and discloses its own limitations. This report is comparability data to support a board's good-faith determination under IRC 4958; it is not legal or tax advice. Generated by PeerBasis on June 9, 2026.